OFAC Compliance Officer Glossary Part 1
Core terms for the role responsible for an organization's OFAC sanctions compliance and screening controls.
TL;DR
TL;DR: A compliance officer is the person accountable for an organization's sanctions compliance program. OFAC expects a designated individual to own the program and its screening controls.
What a compliance officer does
A compliance officer owns the sanctions compliance program: writing policies, overseeing screening, handling escalations, and ensuring the organization blocks prohibited parties. OFAC's guidance treats a committed, empowered compliance officer as a core element of an effective program, and it counts management support as a mitigating factor when a violation occurs. Conversely, a program with no clear owner is seen as weaker and can aggravate a penalty.
Why it matters for agent payments
For an autonomous payment system, the compliance officer's job is to make sure screening is built into the code path, not bolted on later. They set the rules the agent follows: SCREEN the counterparty, SCORE the risk, STOP on a flag, STAMP the decision. The sanctionsai.dev tools sanctions_check, risk_score, kya_verify, and dispute_open give the compliance officer the controls to enforce that 4-Gate protocol, with clean equals ALLOW and flagged equals BLOCK on every transaction.
Terms covered in Part 1
- Compliance officer: the designated owner of the compliance program.
- Escalation: routing a flagged match for review.
- Audit trail: the record of screening decisions kept for review.